You are carrying out your first third-party ISMS surveillance audit as an Audit Team Leader. You are presently in
the auditee's data centre with another member of your audit team.
You are currently in a large room that is subdivided into several smaller rooms, each of which has a numeric
combination lock and swipe card reader on the door. You notice two external contractors using a swipe card and
combination number provided by the centre's reception desk to gain access to a client's suite to carry out authorised electrical repairs.
You go to reception and ask to see the door access record for the client's suite. This indicates only one card was
swiped. You ask the receptionist and they reply, "yes it's a common problem. We ask everyone to swipe their
cards but with contractors especially, one tends to swipe and the rest simply 'tailgate' their way in" but we know who they are from the reception sign-in.
Based on the scenario above which one of the following actions would you now take?
Scenario 5: Data Grid Inc. is a well-known company that delivers security services across the entire information technology infrastructure. It provides cybersecurity software, including endpoint security, firewalls, and antivirus software. For two decades, Data Grid Inc. has helped various companies secure their networks through advanced products and services. Having achieved reputation in the information and network security field, Data Grid Inc. decided to obtain the ISO/IEC 27001 certification to better secure its internal and customer assets and gain competitive advantage.
Data Grid Inc. appointed the audit team, who agreed on the terms of the audit mandate. In addition, Data Grid Inc. defined the audit scope, specified the audit criteria, and proposed to close the audit within five days. The audit team rejected Data Grid Inc.'s proposal to conduct the audit within five days, since the company has a large number of employees and complex processes. Data Grid Inc. insisted that they have planned to complete the audit within five days, so both parties agreed upon conducting the audit within the defined duration. The audit team followed a risk-based auditing approach.
To gain an overview of the main business processes and controls, the audit team accessed process descriptions and organizational charts. They were unable to perform a deeper analysis of the IT risks and controls because their access to the IT infrastructure and applications was restricted. However, the audit team stated that the risk that a significant defect could occur to Data Grid Inc.'s ISMS was low since most of the company's processes were automated. They therefore evaluated that the ISMS, as a whole, conforms to the standard requirements by asking the representatives of Data Grid Inc. the following questions:
•How are responsibilities for IT and IT controls defined and assigned?
•How does Data Grid Inc. assess whether the controls have achieved the desired results?
•What controls does Data Grid Inc. have in place to protect the operating environment and data from malicious software?
•Are firewall-related controls implemented?
Data Grid Inc.'s representatives provided sufficient and appropriate evidence to address all these questions.
The audit team leader drafted the audit conclusions and reported them to Data Grid Inc.'s top management. Though Data Grid Inc. was recommended for certification by the auditors, misunderstandings were raised between Data Grid Inc. and the certification body in regards to audit objectives. Data Grid Inc. stated that even though the audit objectives included the identification of areas for potential improvement, the audit team did not provide such information.
Based on this scenario, answer the following question:
Data Grid Inc. is responsible for all the actions below, EXCEPT:
Scenario 8: EsBank provides banking and financial solutions to the Estonian banking sector since September 2010. The company has a network of 30 branches with over 100 ATMs across the country.
Operating in a highly regulated industry, EsBank must comply with many laws and regulations regarding the security and privacy of data. They need to manage information security across their operations by implementing technical and nontechnical controls. EsBank decided to implement an ISMS based on ISO/IEC 27001 because it provided better security, more risk control, and compliance with key requirements of laws and regulations.
Nine months after the successful implementation of the ISMS, EsBank decided to pursue certification of their ISMS by an independent certification body against ISO/IEC 27001 .The certification audit included all of EsBank’s systems, processes, and technologies.
The stage 1 and stage 2 audits were conducted jointly and several nonconformities were detected. The first nonconformity was related to EsBank’s labeling of information. The company had an information classification scheme but there was no information labeling procedure. As a result, documents requiring the same level of protection would be labeled differently (sometimes as confidential, other times sensitive).
Considering that all the documents were also stored electronically, the nonconformity also impacted media handling. The audit team used sampling and concluded that 50 of 200 removable media stored sensitive information mistakenly classified as confidential. According to the information classification scheme, confidential information is allowed to be stored in removable media, whereas storing sensitive information is strictly prohibited. This marked the other nonconformity.
They drafted the nonconformity report and discussed the audit conclusions with EsBank’s representatives, who agreed to submit an action plan for the detected nonconformities within two months.
EsBank accepted the audit team leader's proposed solution. They resolved the nonconformities by drafting a procedure for information labeling based on the classification scheme for both physical and electronic formats. The removable media procedure was also updated based on this procedure.
Two weeks after the audit completion, EsBank submitted a general action plan. There, they addressed the detected nonconformities and the corrective actions taken, but did not include any details on systems, controls, or operations impacted. The audit team evaluated the action plan and concluded that it would resolve the nonconformities. Yet, EsBank received an unfavorable recommendation for certification.
Based on the scenario above, answer the following question:
Based on scenario 8, EsBank submitted a general action plan. Is this acceptable?
Scenario 6: Sinvestment is an insurance company that offers home, commercial, and life insurance. The company was founded in North Carolina, but have recently expanded in other locations, including Europe and Africa.
Sinvestment is committed to complying with laws and regulations applicable to their industry and preventing any information security incident. They have implemented an ISMS based on ISO/IEC 27001 and have applied for ISO/IEC 27001 certification.
Two auditors were assigned by the certification body to conduct the audit. After signing a confidentiality agreement with Sinvestment. they started the audit activities. First, they reviewed the documentation required by the standard, including the declaration of the ISMS scope, information security policies, and internal audits reports. The review process was not easy because, although Sinvestment stated that they had a documentation procedure in place, not all documents had the same format.
Then, the audit team conducted several interviews with Sinvestment's top management to understand their role in the ISMS implementation. All activities of the stage 1 audit were performed remotely, except the review of documented information, which took place on-site, as requested by Sinvestment.
During this stage, the auditors found out that there was no documentation related to information security training and awareness program. When asked, Sinvestment's representatives stated that the company has provided information security training sessions to all employees. Stage 1 audit gave the audit team a general understanding of Sinvestment's operations and ISMS.
The stage 2 audit was conducted three weeks after stage 1 audit. The audit team observed that the marketing department (which was not included in the audit scope) had no procedures in place to control employees’ access rights. Since controlling employees' access rights is one of the ISO/IEC 27001 requirements and was included in the information security policy of the company, the issue was included in the audit report. In addition, during stage 2 audit, the audit team observed that Sinvestment did not record logs of user activities. The procedures of the company stated that "Logs recording user activities should be retained and regularly reviewed," yet the company did not present any evidence of the implementation of such procedure.
During all audit activities, the auditors used observation, interviews, documented information review, analysis, and technical verification to collect information and evidence. All the audit findings during stages 1 and 2 were analyzed and the audit team decided to issue a positive recommendation for certification.
According to ISO/IEC 27001 requirements, does the company need to provide evidence of implementation of the procedure regarding logs recording user activities? Refer to scenario 6.
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